Post-Implementation Review

Post-implementation review is an important component of high-quality economic analysis of regulatory decision-making. The PCAOB has established a program under which the staff of the Office of Economic and Risk Analysis conducts post-implementation reviews of PCAOB rules and standards.

The objective of the post-implementation review program is to look back at significant rulemakings, after a reasonable period of time has passed, to evaluate the overall effect of the rule or standard. This includes:

Evaluating whether a rule or standard is accomplishing its intended purpose, as identified in the rulemaking release;

Identifying, wherever possible, costs and benefits; and

Identifying unanticipated consequences, either positive or negative.

In connection with this evaluation, the staff will also use the post-implementation review process to gather perspectives on whether rules and standards can be refined or improved.

Post-implementation reviews are intended to complement the prospective economic analysis that PCAOB staff conducts as part of a rulemaking. Over time, it is anticipated that post-implementation reviews will provide useful information for improving prospective economic analyses and informing regulatory decisions. For these reasons, various government agencies, regulators and standard-setters have taken steps to implement retrospective review programs. The PCAOB has considered these initiatives in the development of its own program.

Although post-implementation reviews offer the potential to provide useful information that can serve to enhance the PCAOB's policymaking process, it is also important to recognize challenges and limitations of such reviews. These include isolating the incremental effects of a new standard or rule, dealing with variation across firms and over time, and quantifying effects (especially benefits and indirect costs). Also, because the effects of some PCAOB standards may not be directly observable by some stakeholders, their ability to provide complete information in connection with a review may be limited.

A number of factors are likely to be relevant in deciding whether to perform a post-implementation review of a particular rule or standard and in prioritizing and scoping the work. The staff consults with staff in other offices and divisions and the Board to identify rules or standards that represent candidates for review. In general, the staff expects to perform post-implementation reviews of rules and standards only after a reasonable implementation period has passed so that auditors and other affected parties can adapt, costs and benefits can normalize, and the staff can gather sufficient data to conduct a thorough review regarding the actual effects of the rule or standard.

To perform the reviews, the staff will gather and analyze data from a number of sources, including data collected through the PCAOB's oversight activities. The PCAOB regularly issues Board general reports summarizing information regarding firms' implementation of, and compliance with, new auditing standards. The reports are based on inspection observations from inspection years immediately subsequent to the adoption of the new standard. Post-implementation reviews complement these reports by providing an opportunity to gather additional information from a variety of sources, including firms, preparers, audit committees, investors and others, and to more broadly evaluate the overall effect of a rule or standard, including through economic and statistical analysis of internal and external data relating to periods both before and after adoption.

Although the approach to each post-implementation review will depend upon a number of variables including, for example, the nature of the rule or standard being reviewed and the availability of relevant data, the staff may, among other things:

Review project archives;

Seek comment from interested members of the public;

Solicit input through surveys, questionnaires and interviews;

Review relevant academic and other research;

Conduct analysis of data, including publicly available data and, in particular, data collected through the PCAOB's oversight activities; and